Privacy Policy

Cowan Insurance Group Privacy Policy/Practices

Our Privacy Policy:

Cowan Insurance Group (Cowan) has been in business since 1927.

Cowan has long practiced confidentiality in the handling of all personal information we have collected from our clients. Cowan only uses the information we are given to provide the services for which we have been retained. These services include:

We have designed this Privacy Policy based on the Canadian Standards Association Model Code for the Protection of Personal Information, and the Federal Personal Information Protection and Electronic Documents Act ("PIPEDA"). Within this policy, we will address how the staff, Officers and Directors of the companies of Cowan intend to collect, use, and disclose Personal Information in the context of these principles. This policy reflects Cowan's commitment to the privacy of our clients' Personal Information. Cowan's collection, use and disclosure of their staff's Personal Information is dealt with in a separate policy.

Cowan may disclose Personal Information to any individual or organization for services that are provided to assist us in the conduct of our mandate, including an individual or organization that performs services on our behalf, but only if that individual or organization agrees to use the Personal Information solely for the purposes of performing tasks on behalf of, and under the instruction of, Cowan and, with respect to that information, to act in a manner consistent with the relevant principles articulated in this Privacy Policy.

In order to be certain you are aware of the scope of the information to which our Privacy Policy refers, please note the following definition (as defined in PIPEDA):

Personal Information: Means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. Personal Information includes personal health information with respect to an individual, whether living or deceased, and means (a) information concerning the physical or mental health of the individual; (b) information concerning any health services provided to the individual; (c) information concerning the donation by the individual of any body part or any bodily substance of the individual or information derived from the testing or examination of a body part or bodily substance of the individual; (d) information that is collected in the course of providing health services to the individual; or (e) information that is collected incidentally to the provision of health services to the individual.

Personal Information for the purpose of this policy, shall not include information disclosed as aggregate data. Aggregate data for the purpose of this policy, refers to data that does not reveal, and cannot be manipulated to reveal, member-specific information.

OUR PRIVACY PRACTICES:

1. Accountability
The Personal Information Cowan collects, or is provided, is used and disclosed for the purposes of conducting the services for which we provide. As part of the employment process, our staff, Directors and Officers will sign a confidentiality agreement which outlines Cowan's expectation of its employees to act responsibly in the handling of client information.

In order to further affirm our commitment to maintaining the confidentiality and privacy of our client's personal information, we have done the following:

Cowan's management has developed and adopted this Privacy Policy and is refining our Security, and Records Retention practices.

Cowan has assigned a Privacy Officer to provide client service on matters of privacy relating to Cowan's use, disclosure, security and retention of personal or personal health information. Cowan's Privacy Officer will also be responsible for maintaining this policy and updating staff on changes to both privacy legislation and business practices.

Cowan has held an awareness seminar for key members of staff on privacy legislation and will continue to update all staff on privacy related issues and legislation.

2. Identify the purpose
Cowan collects personal information in the course of providing services to our clients. The following is an example of circumstances in which Cowan may be provided, or required to collect, personal information:

administration and consulting for employer provided life and health benefit plans

integrated health and disability management

group insurance brokerage

human resource consulting

business succession planning

business continuation planning

executive financial planning

3. Obtain consent
Consent to use personal information is required to be obtained at the time of its collection. If Cowan collects the personal information directly from an individual, Cowan will obtain express consent for the collection, use and disclosure of such information. However, Cowan may be contracted by employers to provide third party administration of employer sponsored pension, life and health or general insurance plans. In these cases, personal information may be collected by another party before it is provided to Cowan. Where possible in these circumstances, Cowan will take reasonable measures to require that consent for their use of the personal information has been obtained.

If Cowan uses personal information it has collected, or has been provided, for any reasons other than those disclosed to an individual at the time consent was given, then Cowan will seek to obtain consent for the new use of the information.

4. Limit collection
Cowan limits its collection of personal information to that which is reasonably required to accurately complete the services for which we have been retained. We are committed to respecting the privacy of an individual's personal information and will not collect personal information which is not reasonably required.

5. Limit use, disclosure and retention
Cowan limits its use and disclosure of personal information to the purpose(s) described at the time the information is collected. Cowan retains personal information it collects only as long as is necessary to completely fulfill our services. Cowan maintains a records retention policy. The retention policy has been developed to meet Cowan's record retention requirements consistent with good business practices and known industry standards.

In the event that Cowan decides to purchase, sell, reorganize or transfer the assets of a business, including any Personal Information held by that business, Cowan's client information may be subject to review for such purpose by another party. Should Cowan or such other party wish to use any Personal Information for purposes not described herein, then consent for such use of the information will first be obtained.

Note: As is the case with all companies, Cowan may be lawfully bound to disclose personal information for purposes other than those described at the time consent was obtained. These purposes have been described in applicable privacy legislation as those designed to protect personal and/or public interest.

6. Be accurate
Cowan recognizes that personal information can change. We encourage our clients to keep their personal information current so that we may provide the best services possible. If we are working with a company to manage a company sponsored benefit or pension plan, employee members will be required to inform their employer of any changes to their personal information. Where we have a direct client relationship, personal information can be changed as described on our website, or as directed by our staff upon inquiry by email, phone or fax.

Within a reasonable time of being notified, Cowan will update member records to reflect changes in personal information.

7. Use appropriate safeguards
Cowan has inventoried the various ways in which we store personal information, and has taken reasonable measures to ensure the security of this information within our premises, at our offsite storage locations and in our system databases.

Furthermore, Cowan requires its staff to sign a confidentiality agreement within which is detailed the firm's expectation that staff will respect and safeguard client information. Through this agreement, employees are aware that a breech of confidentiality could result in termination of their employment.

8. Be Open
Cowan's Privacy Officer is mandated to ensure that our Privacy Policy and internal Security and Record Retention Policies are maintained.

Should you wish to question why specific information is required our Privacy Officer is available to answer any such inquiries.

In all matters of privacy, including access requests and privacy concerns, we encourage our clients to contact our Privacy Officer:

9. Give individual access
It is extremely important for clients to know that they have access to their personal information. Requests for personal information held by Cowan, or corrections to such information, can be made by contacting the sponsoring employer, or, in the case of direct client relationships, personal information can be requested or corrected by contacting our Privacy Officer by email, phone or fax. In response to such requests, Cowan will correct or provide that personal information which can be corrected or retrieved at a reasonable cost to Cowan or the sponsoring employer, and will do so in a timely manner. In order to guard against fraudulent requests for access, Cowan will require sufficient information to allow us to confirm the identity of the person making the request before granting access or making corrections.

Note: As is the case with all companies, Cowan may be lawfully bound to deny access of an individual to their personal information. Reasons for such a denial have been described in applicable privacy legislation as those designed to protect personal and/or public interest.

10. Provide recourse
Cowan will review any and all concerns over privacy matters that are submitted to Cowan. Privacy concerns are managed by our Privacy Officer, who provide both a response to the concern as well as contact information for regulatory authorities. Cowan's Privacy Officer will use any concerns to assist in measuring the effectiveness of our Privacy Policy, as well as our business practices. Amendments to our Privacy Policy will be described on our website, along side the updated policy. Whether or not Personal Information already collected and used at Cowan will be affected by any such amendments, will also be discussed on our website along side the notice of the change.